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exclusively used in the operation of its franchise are “exempted” Constitution. Under the latter, the exercise of the power may be
from any property tax. Bayantel’s franchise being national in subject to such guidelines and limitations as the Congress may
character, the “exemption” thus granted under Section 14 of Rep. provide which, however, must be consistent with the basic policy
Act No. 3259 applies to all its real or personal properties found of local autonomy. (at p. 680; Emphasis supplied.)
anywhere within the Philippine archipelago. Same; Same; Same; Same; The Supreme Court has upheld the
Same; Same; Same; Same; The realty tax exemption heretofore power of Congress to grant exemptions over the power of local
enjoyed by Bayantel under its original franchise, but subsequently government units to impose taxes.—In Philippine Long Distance
withdrawn by force of Section 234 of the Local Government Code, Telephone Company, Inc. (PLDT) vs. City of Davao, 363 SCRA 522
has been restored by Section 14 of Republic Act No. 7633.—With (2001), this Court has upheld the power of Congress to grant
the LGC’s taking effect on January 1, 1992, Bayantel’s exemptions over the power of local government units to impose
“exemption” from real estate taxes for properties of whatever kind taxes. There, the Court wrote: Indeed, the grant of taxing
located within the Metro Manila area was, by force of Section 234 powers to local government units under the Constitution
of the Code, expressly withdrawn. But, not long thereafter, and the LGC does not affect the power of Congress to
however, or on July 20, 1992, Congress passed Rep. Act No. 7633 grant exemptions to certain persons, pursuant to a declared
amending Bayantel’s original franchise. Worthy of note is that national policy. The legal effect of the constitutional grant to local
Section 11 of Rep. Act No. 7633 is a virtual reenacment of the tax governments simply means that in interpreting statutory
provision, i.e., Section 14, of Bayantel’s original franchise under provisions on municipal taxing powers, doubts must be resolved
Rep. Act No. 3259. Stated otherwise, Section 14 of Rep. Act No. in favor of municipal corporations.
3259 which was deemed impliedly repealed by Section 234 of the
LGC was expressly revived under Section 14 of Rep. Act No. 7633. PETITION for review on certiorari of the decision and
In concrete terms, the realty tax exemption heretofore enjoyed by resolution of the Regional Trial Court, Br. 227, Quezon
Bayantel under its original franchise, but subsequently City.
withdrawn by force of Section 234 of the LGC, has been restored
by Section 14 of Rep. Act No. 7633. The facts are stated in the opinion of the Court.
The City Attorney for petitioners.
Same; Same; Same; Same; The power to tax is primarily De Mesa, Zaballero & Partners for respondent.
vested in the Congress; however, in our jurisdiction, it may be
exercised by local legislative bodies, no longer merely by virtue of a GARCIA, J.:
valid delegation as before, but pursuant to direct authority
conferred by Section 5, Article X of the Constitution.—Bayantel’s Before the Court, on pure questions of law, is this petition
posture is well-taken. While the system of local government for review on certiorari under Rule 45 of the Rules of Court
taxation has changed with the to nullify and set aside the following issuances of the
Regional Trial Court (RTC) of Quezon City, Branch 227, in
172 its Civil Case No. Q-02-47292, to wit:
173
1
onset of the 1987 Constitution, the power of local government 1) Decision dated June 6, 2003, declaring
units to tax is still limited. As we explained in Mactan Cebu respondent Bayan Telecommunications, Inc.
International Airport Authority: The power to tax is primarily exempt from real estate taxation on its real
vested in the Congress; however, in our jurisdiction, it may be properties located in Quezon City; and
exercised by local legislative bodies, no longer merely by 2
2) Order dated December 30, 2003, denying
virtue of a valid delegation as before, but pursuant to
petitioners’ motion for reconsideration.
direct authority conferred by Section 5, Article X of the
The facts: 3
within the Metro Manila Area the power to levy tax on real
Respondent Bayan Telecommunications, Inc. (Bayantel) properties, thus:
is a legislative4 franchise holder under Republic Act (Rep.
Act) No. 3259 to establish and operate radio stations for SEC. 232. Power to Levy Real Property Tax.—A province or city or
domestic telecommunications, radiophone, broadcasting a municipality within the Metropolitan Manila Area may levy an
and telecasting. annual ad valorem tax on real property such as land, building,
Of relevance to this controversy is the tax provision of machinery and other improvements not hereinafter specifically
Rep. Act No. 3259, embodied in Section 14 thereof, which exempted.
reads:
Complementing the aforequoted provision is the second
SECTION 14. (a) The grantee shall be liable to pay the same paragraph of Section 234 of the same Code which withdrew
taxes on its real estate, buildings and personal property, any exemption from realty tax heretofore granted to or
exclusive of the franchise, as other persons or corporations are enjoyed by all persons, natural or juridical, to wit:
now or hereafter may be required by law to pay. (b) The grantee
SEC. 234. Exemptions from Real Property Tax.—The following are
shall further pay to the Treasurer of the Philippines each year,
exempted from payment of the real property tax:
within ten days after the audit and approval of the accounts as
x x x x x x x x x
prescribed in this Act, one and one-half per centum of all gross
Except as provided herein, any exemption from payment of real
receipts from the busi-
property tax previously granted to, or enjoyed by, all persons,
whether natural or juridical, including government-owned-or-
_______________
controlled corporations is hereby withdrawn upon effectivity
1 Penned by then Judge Vicente Q. Roxas, now Associate Justice of the Court of of this Code (Emphasis supplied).
Appeals; Rollo, pp. 46-71.
On July 20, 1992, barely few months after the LGC took
2 Rollo, p. 72.
effect, Congress enacted Rep. Act No. 7633, amending
3 Formerly named International Communications Corporation.
Bayantel’s original franchise. The amendatory law (Rep.
4 “An Act Granting the International Communications Corporation a Franchise
Act No. 7633) contained the following tax provision:
to Establish Radio Stations for Domestic Telecommunications, Radiophone,
Broadcasting and Telecasting.” Approved on June 17, 1961. SEC. 11. The grantee, its successors or assigns shall be liable to
This franchise was later extended with the enactment of Republic Act No. 4905 pay the same taxes on their real estate, buildings and personal
on June 17, 1967, stating that: “SEC. 4. This franchise shall continue for a period property, exclusive of this franchise, as other persons or
of twenty-five years from the date the first of said stations shall be placed in corporations are now or hereafter may be required by law to pay.
operation, and is granted upon the express condition that the same shall be void In addition thereto, the grantee, its successors or assigns shall
unless the construction of said station be begun within two years from the date of pay a franchise tax equivalent to three percent (3%) of all gross
the approval of this amendatory Act and be completed within four years from said receipts of the tele-
date.”
175
174
It is undisputed that within the territorial boundary of Furthermore, much like the LGC, the QCRC, under its
Quezon City, Bayantel owned several real properties on Section 230, withdrew tax exemption privileges in general,
which it maintained various telecommunications facilities. as follows:
These real properties, as hereunder described, are covered
by the following tax declarations: SEC. 230. Withdrawal of Tax Exemption Privileges.—Unless
otherwise provided in this Code, tax exemptions or incentives
(a) Tax Declaration Nos. D-096-04071, D-096-04074, D- granted to, or presently enjoyed by all persons, whether
096-04072 and D-096-04073 pertaining to natural or juridical, including government owned or controlled
Bayantel’s Head Office and Operations Center in corporations, except local water districts, cooperatives duly
Roosevelt St., San Francisco del Monte, Quezon registered under RA 6938, non-stock and non-profit hospitals and
City allegedly the nerve center of petitioner’s educational institutions, business enterprises certified by the
telecommunications franchise operations, said Board of Investments (BOI) as pioneer or non-pioneer for a period
Operation Center housing mainly petitioner’s of six (6) and four (4) years, respectively, . . . are hereby
Network Operations Group and switching, withdrawn effective upon approval of this Code (Emphasis
transmission and related equipment; supplied).
(b) Tax Declaration Nos. D-124-01013, D-124-00939, D-
Conformably with the City’s Revenue Code, new tax
124-00920 and D-124-00941 covering Bayantel’s
declarations for Bayantel’s real properties in Quezon City
land, building and equipment in Maginhawa St.,
were issued by the City Assessor and were received by
Barangay East Teacher’s Village, Quezon City
Bayantel on August 13, 1998, except one (Tax Declaration
which houses telecommunications facilities; and
No. 124-01013) which was received on July 14, 1999.
(c) Tax Declaration Nos. D-011-10809, D-011-10810, D-
6
Meanwhile, on March 16, 1995, Rep. Act No. 7925,
011-10811, and D-011-11540 referring to Bayantel’s otherwise known as the “Public Telecommunications Policy
Exchange Center located in Proj. 8, Brgy. Bahay Act of the Philippines,” envisaged to level the playing field
Toro, Tandang Sora, Quezon City which houses the among telecommunications companies, took effect. Section
Network Operations Group and cover switching, 23 of the Act provides:
transmission and other related equipment.
SEC. 23. Equality of Treatment in the Telecommunications
In 1993, the government of Quezon City, pursuant to the Industry.—Any advantage, favor, privilege, exemption, or
taxing power vested on local government units by Section immunity granted under existing franchises, or may hereafter be
5, Article X of the 1987 Constitution, infra, in relation to granted, shall ipso facto become part of previously granted
Section 232 of the LGC, supra, enacted City Ordinance No. telecommunications franchises and shall be accorded immediately
SP-91, S-93, otherwise known as the Quezon City Revenue and unconditionally to the grantees of such franchises: Provided,
5
Code (QCRC), imposing, under Section 5 thereof, a real however, That the foregoing shall neither apply to nor affect
property tax on all real properties in Quezon City, and, provisions of telecommunications franchises concerning territory
reiterating in covered by the franchise, the life
_______________ _______________
5 This took effect on July 1, 1993. 6 Entitled “An Act to Promote and Govern the Development of Philippine
Telecommunications and the Delivery of Public Telecommunication Services.”
176
177
span of the franchise, or the type of service authorized by the (5) Tax Declaration No. D-011-10811—
franchise. (6) Tax Declaration No. D-011-10809—
(7) Tax Declaration No. D-124-00941—
On January 7, 1999, Bayantel wrote the office of the City
Assessor seeking the exclusion of its real properties in the (8) Tax Declaration No. D-124-00940—
city from the roll of taxable real properties. With its (9) Tax Declaration No. D-124-00939—
request having been denied, Bayantel interposed an appeal (10) Tax Declaration No. D-096-04072—
with the Local Board of Assessment Appeals (LBAA). And, (11) Tax Declaration No. D-096-04073—
evidently on its firm belief of its exempt status, Bayantel
(12) Tax Declaration No. D-011-11540—
did not pay the real property taxes assessed against it by
the Quezon City government.
The preliminary prohibitory injunction issued in the August
On account thereof, the Quezon City Treasurer sent out
20, 2002 Order of this Court is hereby made permanent. Since
notices of delinquency for the total amount of
this is a resolution of a purely legal issue, there is no
P43,878,208.18, followed by the issuance of several
pronouncement as to costs.
warrants of levy against Bayantel’s properties preparatory
SO ORDERED.”
to their sale at a public auction set on July 30, 2002.
Threatened with the imminent loss of its properties, Their motion for reconsideration having been denied by the
Bayantel immediately withdrew its appeal with the LBAA court in its Order dated December 30, 2003, petitioners
and instead filed with the RTC of Quezon City a petition elevated the case directly to this Court on pure questions of
for prohibition with an urgent application for a temporary law, ascribing to the lower court the following errors:
restraining order (TRO) and/or writ of preliminary
injunction, thereat docketed as Civil Case No. Q-02-47292, I. [I]n declaring the real properties of respondent
which was raffled to Branch 227 of the court. exempt from real property taxes notwithstanding
On July 29, 2002, or in the eve of the public auction the fact that the tax exemption granted to Bayantel
scheduled the following day, the lower court issued a TRO, in its original franchise had been withdrawn by the
followed, after due hearing, by a writ of preliminary [LGC] and that the said exemption was not restored
injunction via its order of August 20, 2002. by the enactment of RA 7633.
And, having heard the parties on the merits, the same II. [In] declaring the real properties of respondent
court came out with its challenged Decision of June 6, exempt from real property taxes notwithstanding
2003, the dispositive portion of which reads: the enactment of the [QCRC] which withdrew the
tax exemption which may have been granted by RA
“WHEREFORE, premises considered, pursuant to the enabling
7633.
franchise under Section 11 of Republic Act No. 7633, the real
estate properties and buildings of petitioner [now, respondent III. [In] declaring the real properties of respondent
Bayantel] which have been admitted to be used in the operation of exempt from real property taxes notwithstanding
petitioner’s franchise described in the following tax declarations the vague and ambiguous grant of tax exemption
are hereby DECLARED exempt from real estate taxation: provided under Section 11 of RA 7633.
IV. [In] declaring the real properties of respondent
178 exempt from real property taxes notwithstanding
the fact that [it] had failed
178 SUPREME COURT REPORTS ANNOTATED
179
City Government of Quezon City vs. Bayan Telecommunications,
Inc.
VOL. 484, MARCH 6, 2006 179
(1) Tax Declaration No. D-096-04071—
City Government of Quezon City vs. Bayan
(2) Tax Declaration No. D-096-04074— Telecommunications, Inc.
(3) Tax Declaration No. D-124-01013—
(4) Tax Declaration No. D-011-10810—
180
VOL. 484, MARCH 6, 2006 181
City Government of Quezon City vs. Bayan
180 SUPREME COURT REPORTS ANNOTATED Telecommunications, Inc.
City Government of Quezon City vs. Bayan
Telecommunications, Inc.
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rate and extensive discussion devoted by the trial court on those exclusive of its franchise, are subject to realty
the meaning and import of said phrase, they add, suggests taxes. Ultimately, therefore, the inevitable result was that
as much. It is petitioners’ thesis that Bayantel was in no all realties which are actually, directly and exclusively
time given any express exemption from the payment of used in the operation of its franchise are “exempted” from
real property tax under its amendatory franchise. any property tax.
There seems to be no issue as to Bayantel’s exemption Bayantel’s franchise being national in character, the
from real estate taxes by virtue of the term “exclusive of “exemption” thus granted under Section 14 of Rep. Act No.
the franchise” qualifying the phrase “same taxes on its real 3259 applies to all its real or personal properties found
estate, buildings and personal property,” found in Section anywhere within the Philippine archipelago.
14, supra, of its franchise, Rep. Act No. 3259, as originally However, with the LGC’s taking effect on January 1,
granted. 1992, Bayantel’s “exemption” from real estate taxes for
The legislative intent expressed in the phrase “exclusive properties of whatever kind located within the Metro
of this franchise” cannot be construed other than Manila area was, by force of Section 234 of the Code, supra,
distinguishing between two (2) sets of properties, be they expressly withdrawn. But, not long thereafter, however, or
real or personal, owned by the franchisee, namely, (a) those on July 20, 1992, Congress passed Rep. Act No. 7633
actually, directly and exclusively used in its radio or amending Bayantel’s original franchise. Worthy of note is
telecommunications business, and (b) those properties that Section 11 of Rep. Act No. 7633 is a virtual
which are not so used. It is worthy to note that the reenacment of the tax provision, i.e., Section 14, supra, of
properties subject of the present controversy are only those Bayantel’s original franchise under Rep. Act No. 3259.
which are admittedly falling under the first category. Stated otherwise, Section 14 of Rep. Act No. 3259 which
To the mind of the Court, Section 14 of Rep. Act No. was deemed impliedly repealed by Section 234 of the LGC
3259 effectively works to grant or delegate to local was expressly revived under Section 14 of Rep. Act No.
governments of Congress’ inherent power to tax the 7633. In concrete terms, the realty tax exemption
franchisee’s properties belonging to the second group of heretofore enjoyed by Bayantel under its original franchise,
properties indicated above, that is, all properties which, but subsequently withdrawn by force of Section 234 of the
“exclusive of this franchise,” are not actually and directly LGC, has been restored by Section 14 of Rep. Act No. 7633.
used in the pursuit of its franchise. As may be recalled, the The Court has taken stock of the fact that by virtue
8
of
taxing power of local governments under both the 1935 and Section 5, Article X of the 1987 Constitution, local
the 1973 Constitutions solely depended upon an enabling governments
law. Absent such enabling law, local government units
were without authority to impose and collect taxes on real _______________
properties within their respective territorial jurisdictions.
While Section 14 of Rep. Act No. 3259 may be validly 8 Sec. 5. Each local government unit shall have the power to create its
viewed as an implied delegation of power to tax, the own sources of revenues and to levy taxes . . . subject to such guidelines
delegation under that provision, as couched, is limited to and limitations as the Congress may provide, consistent with the basic
impositions over properties of the franchisee which are not policy of local autonomy. x x x. Mactan Cebu International Airport
actually, directly and exclusively used in the pursuit of its Authority vs. Marcos, 261 SCRA 667 (1996), per then Associate Justice,
franchise. Necessarily, other properties of Bayantel directly now retired Chief Justice Hilario G. Davide, Jr., ponente.
182 183
182 SUPREME COURT REPORTS ANNOTATED VOL. 484, MARCH 6, 2006 183
City Government of Quezon City vs. Bayan City Government of Quezon City vs. Bayan
Telecommunications, Inc. Telecommunications, Inc.
used in the pursuit of its business are beyond the pale of are empowered to levy taxes. And pursuant to this9
the delegated taxing power of local governments. In a very constitutional empowerment, juxtaposed with Section 232
real sense, therefore, real properties of Bayantel, save of the LGC, the Quezon City government enacted in 1993
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its local Revenue Code, imposing real property tax on all Constitution now in place, .the basic doctrine on local
real properties found within its territorial jurisdiction. And taxation remains essentially the same. For as the Court
as earlier stated, the City’s Revenue Code, just like the stressed in Mac-tan, “the power to tax is [still]
LGC, expressly withdrew, under Section 230 thereof, primarily vested in the Congress.”
supra, all tax exemption privileges in general. This new perspective is best articulated by Fr. Joaquin
This thus raises the question of whether or not the G. Bernas, S.J., himself a Commissioner of the 1986
City’s Revenue Code pursuant to which the city treasurer of Constitutional Commission which crafted the 1987
Quezon City levied real property taxes against Bayantel’s Constitution, thus:
real properties located within the City effectively withdrew
the tax exemption enjoyed by Bayantel under its franchise, “What is the effect of Section 5 on the fiscal position of municipal
as amended. corporations? Section 5 does not change the doctrine that
Bayantel answers the poser in the negative arguing that municipal corporations do not possess inherent powers of
once again it is only “liable to pay the same taxes, as any taxation. What it does is to confer municipal corporations
other persons or corporations on all its real or personal a general power to levy taxes and otherwise create sources
properties, exclusive of its franchise.” of revenue. They no longer have to wait for a statutory grant of
Bayantel’s posture is well-taken. While the system of these powers. The power of the legislative authority relative to
local government taxation has changed with the onset of the fiscal powers of local governments has been reduced to the
the 1987 Constitution, the power of local government units authority to impose limitations on municipal powers. Moreover,
to tax is still limited. As we explained in Mactan Cebu these limitations must be “consistent with the basic policy of local
International Airport Authority:
10
autonomy.” The important legal effect of Section 5 is thus to
reverse the principle that doubts are resolved against
The power to tax is primarily vested in the Congress; however, in municipal corporations. Henceforth, in interpreting statutory
our jurisdiction, it may be exercised by local legislative bodies, no provisions on municipal fiscal powers, doubts will be resolved in
longer merely be virtue of a valid delegation as before, but favor of municipal corporations. It is understood, however, that
pursuant to direct authority conferred by Section 5, Article X of the taxes imposed by local government must be for a public purpose,
Constitution. Under the latter, the exercise of the power may be uniform within a locality, must not be confiscatory, 11and must be
subject to such guidelines and limitations as the Congress may within the jurisdiction of the local unit to pass.” (Emphasis
provide which, however, must be consistent with the basic policy supplied.)
of local autonomy. (at p. 680; Emphasis supplied.)
In net effect, the controversy presently before the Court
involves, at bottom, a clash between the inherent taxing
_______________
power of the legislature, which necessarily includes the
9 SEC. 232. Power to Levy Real Property Tax.—A province or city or power to exempt, and the local government’s delegated
municipality within the Metropolitan Manila Area may levy an annual ad power to tax under the aegis of the 1987 Constitution.
valorem tax on real property such as land, building, machinery, and other
improvement not hereinafter specifically exempted. _______________
10 See Footnote #8, supra.
11 Bernas, The Constitution of the Republic of the Philippines, a
184 Commentary, Vol. 11, 1988 ed., p. 381.
185
184 SUPREME COURT REPORTS ANNOTATED
City Government of Quezon City vs. Bayan VOL. 484, MARCH 6, 2006 185
Telecommunications, Inc.
City Government of Quezon City vs. Bayan
Telecommunications, Inc.
Clearly then, while a new slant on the subject of local
taxation now prevails in the sense that the former doctrine
of local government units’ delegated power to tax had been Now to go back to the Quezon City Revenue Code which
effectively modified with Article X, Section 5 of the 1987 imposed real estate taxes on all real properties within the
city’s territory and removed exemptions theretofore ties from realty taxes by its enactment of Rep. Act No. 7633
“previously granted to, or presently
12
enjoyed by all persons, which amended Bayantel’s original franchise. The more
whether natural or juridical ….,” there can really be no decisive question turns on whether Congress
dispute that the power of the Quezon City Government to actually did exempt Bayantel’s properties at all by
tax is limited by Section 232 of the LGC which expressly virtue of Section 11 of Rep. Act No. 7633.
provides that “a province or city or municipality within the Admittedly, Rep. Act No. 7633 was enacted subsequent
Metropolitan Manila Area may levy an annual ad valorem to the LGC. Perfectly aware that the LGC has already
tax on real property such as land, building, machinery, and withdrawn Bayantel’s former exemption from realty taxes,
other improvement not hereinafter specifically Congress opted to pass Rep. Act No. 7633 using, under
exempted.” Under this law, the Legislature highlighted its Section 11 thereof, exactly the same defining phrase
power to thereafter exempt certain realties from the taxing “exclusive of this franchise” which was the basis for
power of local government units. An interpretation denying Bayantel’s exemption from realty taxes prior to the LGC.
Congress such power to exempt would reduce the phrase In plain language, Section 11 of Rep. Act No. 7633 states
“not hereinafter specifically exempted” as a pure jargon, that “the grantee, its successors or assigns shall be liable to
without meaning whatsoever. Needless to state, such pay the same taxes on their real estate, buildings and
absurd situation is unacceptable. personal property, exclusive of this franchise, as other
For sure, in Philippine Long Distance 13
Telephone persons or corporations are now or hereafter may be
Company, Inc. (PLDT) vs. City of Davao, this Court has required by law to pay.” The Court views this subsequent
upheld the power of Congress to grant exemptions over the piece of legislation as an express and real intention on
power of local government units to impose taxes. There, the the part of Congress to once again remove from the
Court wrote: LGC’s delegated taxing power, all of the franchisee’s
(Bayantel’s) properties that are actually, directly and
Indeed, the grant of taxing powers to local government exclusively used in the pursuit of its franchise.
units under the Constitution and the LGC does not affect WHEREFORE, the petition is DENIED.
the power of Congress to grant exemptions to certain No pronouncement as to costs.
persons, pursuant to a declared national policy. The legal effect of SO ORDERED.
the constitutional grant to local governments simply means that
in interpreting statutory provisions on municipal taxing powers, Puno (Chairperson), Sandoval-Gutierrez, Corona
doubts must be resolved in favor of municipal corporations. and Azcuna, JJ., concur.
(Emphasis supplied.)
Petition denied.
As we see it, then, the issue in this case no longer dwells on
whether Congress has the power to exempt Bayantel’s Notes.—Any exemption from the payment of a tax must
proper- be clearly stated in the language of the law. (Commissioner
of Internal Revenue vs. Court of Appeals, 329 SCRA 237
_______________ [2000])
——o0o——
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